"Underground euthanasia" and the harm minimization debate

Journal of Law, Medicine and Ethics

Volumn 32, Issue 3, 2004, Pages 486-495

  Magnusson, Roger S ^a  

^a UNIVERSITY OF SYDNEY   (Australia)

Author keywords

[No Author keywords available]

Indexed keywords

ASSISTED SUICIDE; AUSTRALIA; EUTHANASIA; HEALTH CARE POLICY; HUMAN; LEGAL ASPECT; MEDICAL PRACTICE; PATIENT CARE; REVIEW;

EID: 4944243976     PISSN: 10731105     EISSN: None     Source Type: Journal    
DOI: 10.1111/j.1748-720X.2004.tb00161.x     Document Type: Review

References (95)

1. D.E. Meier, C.A. Emmons, S. Wallenstein et al., "A National Survey of Physician-Assisted Suicide and Euthanasia in the United States," N. Engl. J. Med. 338 (1998): 1193-1201.
2. E.J. Emanuel, D. Fairclough, B. Clarridge et al, "Attitudes and Practices of U.S. Oncologists Regarding Euthanasia and Physician-Assisted Suicide," Annals of Internal Medicine 133 (2000): 527-32.
3. R.J. Kohlwes, T.D. Koepsell, L.A. Rhodes, and R.A. Pearlman, "Physicians' Responses to Patients' Requests for Physician-Assisted Suicide," Archives of Internal Medicine 161 (2001): 657-63.
4. C.D. Douglas, L.H. Kerridge, K.J. Rainbird et al., "The Intention to Hasten Death: A Survey of Attitudes and Practices of Surgeons in Australia," Medical Journal of Australia 175 (2001): 511-15.
5. H. Kuhse, P. Singer, P. Baume et al., "End-of-Life Decisions in Australian Medical Practice," Medical Journal of Australia 166 (1997): 191-96.
6. R.S. Magnusson, Angels of Death: Exploring the Euthanasia Underground (New Haven, Connecticut & London: Yale University Press, 2002).
7. Magnusson, supra note 6, at 130-38.
8. E.J. Emanuel, E.R. Daniels, D.L. Fairclough et al., "The Practice of Euthanasia and Physician-Assisted Suicide in the United States: Adherence to Proposed Safeguards and Effects on Physicians," JAMA 280 (1998): 507-13.
9. J.H. Groenewoud, A. van der Heide, B.D. Onwuteaka-Philipsen et al., "Clinical Problems with the Performance of Euthanasia and Physician-Assisted Suicide in the Netherlands," N. Engl. J. Med. 342 (2000): 551-56.
10. D. Hillyard and J. Dombrink, Dying Right: The Death With Dignity Movement (New York: Routledge, 2001): at 186.
11. Magnusson, supra note 6, at 9, 168, 208-09.
12. Kuhse, supra note 5, at 193.
13. Emanuel, supra note 8, at 511.
14. See, e.g., S.H. Miles, "Physicians and Their Patients' Suicides," JAMA 217 (1994): 1786-88; B. J. Pollard, "Can Euthanasia Be Safely Legalized?," Pazliative Medicine, 15 (2001): 61-65; T. Quill, C.K. Cassel, and D.E. Meier, "Care of the Hopelessly Ill: Proposed Clinical Criteria for Physician-Assisted Suicide," N. Engl. J. Med. 327 (1992): 1380-84; K. Amarasekara, "Euthanasia and the Quality of Legislative Safeguards," Monash University Law Review 23 (1997): 1-42.
15. See, e.g., S.H. Miles, "Physicians and Their Patients' Suicides," JAMA 217 (1994): 1786-88; B. J. Pollard, "Can Euthanasia Be Safely Legalized?," Pazliative Medicine, 15 (2001): 61-65; T. Quill, C.K. Cassel, and D.E. Meier, "Care of the Hopelessly Ill: Proposed Clinical Criteria for Physician-Assisted Suicide," N. Engl. J. Med. 327 (1992): 1380-84; K. Amarasekara, "Euthanasia and the Quality of Legislative Safeguards," Monash University Law Review 23 (1997): 1-42.
16. See, e.g., S.H. Miles, "Physicians and Their Patients' Suicides," JAMA 217 (1994): 1786-88; B. J. Pollard, "Can Euthanasia Be Safely Legalized?," Pazliative Medicine, 15 (2001): 61-65; T. Quill, C.K. Cassel, and D.E. Meier, "Care of the Hopelessly Ill: Proposed Clinical Criteria for Physician-Assisted Suicide," N. Engl. J. Med. 327 (1992): 1380-84; K. Amarasekara, "Euthanasia and the Quality of Legislative Safeguards," Monash University Law Review 23 (1997): 1-42.
17. See, e.g., S.H. Miles, "Physicians and Their Patients' Suicides," JAMA 217 (1994): 1786-88; B. J. Pollard, "Can Euthanasia Be Safely Legalized?," Pazliative Medicine, 15 (2001): 61-65; T. Quill, C.K. Cassel, and D.E. Meier, "Care of the Hopelessly Ill: Proposed Clinical Criteria for Physician-Assisted Suicide," N. Engl. J. Med. 327 (1992): 1380-84; K. Amarasekara, "Euthanasia and the Quality of Legislative Safeguards," Monash University Law Review 23 (1997): 1-42.
18. M. Somerville, Death Talk: The Case Against Euthanasia and Physician-Assisted Suicide (Montreal & Kingston: McGill-Queen's University Press, 2001): at 54. In fairness to Somerville, she adds that "I am assuming here that hidden euthanasia involves only those who want to be killed and who would be eligible for euthanasia if it were legalized." I would argue that the evidence does not bear out this assumption. See Magnusson, supra note 6, at 200-44.
19. Magnusson, supra note 6, at 174-99.
20. Cf. D. Callahan and M. White, "The Legalization of Physician-Assisted Suicide: Creating a Regulatory Potemkin Village," University of Richmond Law Review 30 (1996): 1-83, at 8-9.
21. F. Lewins, "The Development of Bioethics and the Issue of Euthanasia: Regulating, De-regulating or Re-regulating," Journal of Sociology 34, no. 2 (1998): 123-34, at 132.
22. Magnusson, supra note 6, at 145-47.
23. See J.A. Billings and S.D. Block, "Slow Euthanasia," Journal of Palliative Care 12 (1996): 21-30; E.H. Loewy, "Terminal Sedation, Self-Starvation, and Orchestrating the End of Life," Archives of Internal Medicine 161 (2001): 329-32.
24. See J.A. Billings and S.D. Block, "Slow Euthanasia," Journal of Palliative Care 12 (1996): 21-30; E.H. Loewy, "Terminal Sedation, Self-Starvation, and Orchestrating the End of Life," Archives of Internal Medicine 161 (2001): 329-32.
25. Examples include F. Cohn and J. Lynn, "Vulnerable People: Practical Rejoinders to Claims in Favor of Assisted Suicide," in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 238-60, at 251-55; K. Amarasekara, "Euthanasia and the Quality of Legislative Safeguards," Monash University Law Review 23 (1997): 1-42.
26. Examples include F. Cohn and J. Lynn, "Vulnerable People: Practical Rejoinders to Claims in Favor of Assisted Suicide," in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 238-60, at 251-55; K. Amarasekara, "Euthanasia and the Quality of Legislative Safeguards," Monash University Law Review 23 (1997): 1-42.
27. New York State Task Force on Life & the Law, When Death is Sought: Assisted Suicide and Euthanasia in the Medical Context (New York: The New York State Task Force on Life & the Law, 1994): at 120 (emphasis added).
28. Id., at 120.
29. B. Pollard, "Can Euthanasia Be Safely Legalized?" Palliative Medicine 15 (2001): 61-65, at 62.
30. D. Callahan, "When Self-Determination Runs Amok," Hastings Center Report 22 (1992): 52-55, at 53. See also D. Callahan, "Reason, Self-Determination and Physician-Assisted Suicide" in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 52-68, at 60.
31. D. Callahan, "When Self-Determination Runs Amok," Hastings Center Report 22 (1992): 52-55, at 53. See also D. Callahan, "Reason, Self-Determination and Physician-Assisted Suicide" in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 52-68, at 60.
32. D. Callahan, "Regulating Physician-Assisted Death," N. Engl. J. Med. 331 (1994): 1656.
33. Byock, for example, claims that "with the skillful application of psychosocial and spiritual support, dying often becomes an extremely important, valuable and, not rarely, a privileged time in life." I. Byock, "The Hospice Clinician's Response to Euthanasia/Physician Assisted Suicide," The Hospice Journals (1994): 1-8, at 6. See also R.S. Magnusson, "Challenges and Dilemmas in the Aging and Euthanasia' Policy Cocktail," in D. H. Weisstub, D. C. Thomasma, S. Gauthier, and G. Tomossy, eds., Aging: Decisions at the End of Life (Dordrecht: Kluwer Academic Publishers, 2001): at 113-14, 121-22.
34. Byock, for example, claims that "with the skillful application of psychosocial and spiritual support, dying often becomes an extremely important, valuable and, not rarely, a privileged time in life." I. Byock, "The Hospice Clinician's Response to Euthanasia/Physician Assisted Suicide," The Hospice Journals (1994): 1-8, at 6. See also R.S. Magnusson, "Challenges and Dilemmas in the Aging and Euthanasia' Policy Cocktail," in D. H. Weisstub, D. C. Thomasma, S. Gauthier, and G. Tomossy, eds., Aging: Decisions at the End of Life (Dordrecht: Kluwer Academic Publishers, 2001): at 113-14, 121-22.
35. K. Foley and H. Hendin, "The Oregon Experiment," in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 144-74, at 150.
36. Id. at 148.
37. See id. at 151, 160-61, 164, respectively.
38. See D.J. Cook, G. Guyatt, R. Jaeschke, J. Reeve, A. Spanier et al., "Determinants in Canadian Health Care Workers of the Decision to Withdraw Life Support from the Critically Ill," Journal of the American Medical Association 273 (1995): 703-08.
39. A. L. Caplan, L. Snyder, and K. Faber-Langendoen, for the University of Pennsylvania Center for Bioethics Assisted Suicide Consensus Panel, "The Role of Guidelines in the Practice of Physician-Assisted Suicide," Annals of Internal Medicine 132 (2000): 476-81, at 478-79.
40. Callahan, supra note 26, at 1656.
41. Hillyard and Dombrink note that all physician reports were in full compliance with the law in 1998. See Hillyard and Dombrink, supra note 10, at 186. In 1999 Sullivan and colleagues reported full compliance "as best we could determine": A.D. Sullivan, K. Hedberg, and D.W. Fleming, "Legalized Physician-Assisted Suicide in Oregon - The Second Year," N. Engl J. Med. 342 (2000): 598-604, at 603. One physician was reported in 2000. Id. at 605-07.
42. Jochemsen surveys evidence of non-compliance with the criteria required to be established for the purposes of the necessity defense, prior to the introduction of the Termination of Life on Request and Assisted Suicide (Review Procedures) Act: H. Jochemsen, "Why Euthanasia Should Not Be Legalized," in D.H. Weisstub, D.C. Thomasma, S. Gauthier and G. Tomossy, eds., Aging: Decisions at the End of Life (Dordrecht: Kluwer Academic Publishers, 2001): 67-90, at 71-78. Similarly, see H. Hendin, "The Dutch Experience," in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 97-121, at 103ff; J. Keown, Euthanasia, Ethics and Public Policy: An Argument Against Legalization (Cambridge: Cambridge University Press, 2002): at 103-24. Although initially acknowledged in case law, guidance as to the scope of the necessity defense was also found in the statutory notification procedure that applied to euthanasia deaths under burial legislation. That procedure included some fifty criteria which acted as guidelines for the public prosecutor when assessing doctors' reports. See, further, J. Griffiths, A. Bood, and H. Weyers, Euthanasia & the Law in the Netherlands (Amsterdam: Amsterdam University Press, 1998): 114-16.
43. Jochemsen surveys evidence of non-compliance with the criteria required to be established for the purposes of the necessity defense, prior to the introduction of the Termination of Life on Request and Assisted Suicide (Review Procedures) Act: H. Jochemsen, "Why Euthanasia Should Not Be Legalized," in D.H. Weisstub, D.C. Thomasma, S. Gauthier and G. Tomossy, eds., Aging: Decisions at the End of Life (Dordrecht: Kluwer Academic Publishers, 2001): 67-90, at 71-78. Similarly, see H. Hendin, "The Dutch Experience," in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 97-121, at 103ff; J. Keown, Euthanasia, Ethics and Public Policy: An Argument Against Legalization (Cambridge: Cambridge University Press, 2002): at 103-24. Although initially acknowledged in case law, guidance as to the scope of the necessity defense was also found in the statutory notification procedure that applied to euthanasia deaths under burial legislation. That procedure included some fifty criteria which acted as guidelines for the public prosecutor when assessing doctors' reports. See, further, J. Griffiths, A. Bood, and H. Weyers, Euthanasia & the Law in the Netherlands (Amsterdam: Amsterdam University Press, 1998): 114-16.
44. Jochemsen surveys evidence of non-compliance with the criteria required to be established for the purposes of the necessity defense, prior to the introduction of the Termination of Life on Request and Assisted Suicide (Review Procedures) Act: H. Jochemsen, "Why Euthanasia Should Not Be Legalized," in D.H. Weisstub, D.C. Thomasma, S. Gauthier and G. Tomossy, eds., Aging: Decisions at the End of Life (Dordrecht: Kluwer Academic Publishers, 2001): 67-90, at 71-78. Similarly, see H. Hendin, "The Dutch Experience," in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 97-121, at 103ff; J. Keown, Euthanasia, Ethics and Public Policy: An Argument Against Legalization (Cambridge: Cambridge University Press, 2002): at 103-24. Although initially acknowledged in case law, guidance as to the scope of the necessity defense was also found in the statutory notification procedure that applied to euthanasia deaths under burial legislation. That procedure included some fifty criteria which acted as guidelines for the public prosecutor when assessing doctors' reports. See, further, J. Griffiths, A. Bood, and H. Weyers, Euthanasia & the Law in the Netherlands (Amsterdam: Amsterdam University Press, 1998): 114-16.
45. Jochemsen surveys evidence of non-compliance with the criteria required to be established for the purposes of the necessity defense, prior to the introduction of the Termination of Life on Request and Assisted Suicide (Review Procedures) Act: H. Jochemsen, "Why Euthanasia Should Not Be Legalized," in D.H. Weisstub, D.C. Thomasma, S. Gauthier and G. Tomossy, eds., Aging: Decisions at the End of Life (Dordrecht: Kluwer Academic Publishers, 2001): 67-90, at 71-78. Similarly, see H. Hendin, "The Dutch Experience," in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 97-121, at 103ff; J. Keown, Euthanasia, Ethics and Public Policy: An Argument Against Legalization (Cambridge: Cambridge University Press, 2002): at 103-24. Although initially acknowledged in case law, guidance as to the scope of the necessity defense was also found in the statutory notification procedure that applied to euthanasia deaths under burial legislation. That procedure included some fifty criteria which acted as guidelines for the public prosecutor when assessing doctors' reports. See, further, J. Griffiths, A. Bood, and H. Weyers, Euthanasia & the Law in the Netherlands (Amsterdam: Amsterdam University Press, 1998): 114-16.
46. G. van der Wal, P.J. van der Maas, J.M. Bosnia, B.D. Onwuteaka-Philipsen, D.L. Willems et al., "Evaluation of the Notification Procedure for Physician-Assisted Death in the Netherlands," N. Engl. J. Med. 335 (1996): 1706-11.
47. B.D. Onwuteaka-Philipsen, G. van der Wal, P.J. Kostense, and P. J. van der Maas, "Consultants in Cases of Intended Euthanasia or Assisted Suicide in the Netherlands," Medical Journal of Australia 170 (1999): 360-363 (confirming that the consultant saw the patient in 88 percent of cases).
48. H. Hendin, "Euthanasia Consultants or Facilitators?," Medical Journal of Australia 170 (1999): 351-52.
49. R. Cohen-Almagor, "An Outsider's View of Dutch Euthanasia Policy and Practice," Issues in Law & Medicine 17 (2001): 35-68, at 66.
50. Jochemsen, supra note 35, at 77.
51. See P.J. van der Maas, G. van der Wal, I. Haverkate, C.L.M. de Graaff, J.G.C. Kester, B.D. Onwuteaka-Philipsen et al., "Euthanasia, Physician-Assisted Suicide, and Other Medical Practices Involving the End of Life in the Netherlands, 1990-1995," N. Engl. J. Med. 335 (1996): 1699-1705; P.J. van der Maas, J. J.M. van Delden, L. Pijnenborg, "Euthanasia and Other Medical Decisions Concerning the End of Life," The Lancet 338 (1991): 669-74.
52. See P.J. van der Maas, G. van der Wal, I. Haverkate, C.L.M. de Graaff, J.G.C. Kester, B.D. Onwuteaka-Philipsen et al., "Euthanasia, Physician-Assisted Suicide, and Other Medical Practices Involving the End of Life in the Netherlands, 1990-1995," N. Engl. J. Med. 335 (1996): 1699-1705; P.J. van der Maas, J. J.M. van Delden, L. Pijnenborg, "Euthanasia and Other Medical Decisions Concerning the End of Life," The Lancet 338 (1991): 669-74.
53. H. Kuhse, P. Singer, P. Baume et al, supra, note 5.
54. J. Griffiths, "Human Rights and Euthanasia," MBPSL Newsletter, no. 5 (2001): at 2, available at 〈http://www.rug.nl/law/research/ programmes/ mbpsl/researchprogram/newsletters/〉 (accessed July 22, 2004).
55. B.J. Ward and P.A. Tate, "Attitudes Among NHS Doctors to Requests for Euthanasia," British Medical Journal 308 (1994): 1332-34. Thirty-eight respondents (9 percent) responded affirmatively to the question: "Have you ever taken active steps to bring about the death of a patient who asked you to do so?"
56. J. Keown, Euthanasia, Ethics and Public Policy: An Argument Against Legalization (Cambridge: Cambridge University Press, 2002): at 61.
57. Id. at 62.
58. Meier, supra note 1; Douglas, supra note 4, respectively.
59. Keown, supra note 45, at 61.
60. H.J. Chochinov, D. Tataryn, J.J. Clinch, and D. Dudgeon, "Will to Live in the Terminally Ill," The Lancet 354 (1999): 816-19; see also E.J. Emanuel, D.L. Fairclough, L.L. Emanuel, "Attitudes and Desires Related to Euthanasia and Physician-Assisted Suicide Among Terminally Ill Patients and their Caregivers," JAMA 284 (2000): 2460-68.
61. H.J. Chochinov, D. Tataryn, J.J. Clinch, and D. Dudgeon, "Will to Live in the Terminally Ill," The Lancet 354 (1999): 816-19; see also E.J. Emanuel, D.L. Fairclough, L.L. Emanuel, "Attitudes and Desires Related to Euthanasia and Physician-Assisted Suicide Among Terminally Ill Patients and their Caregivers," JAMA 284 (2000): 2460-68.
62. B.J. Pollard, "Can Euthanasia Be Safely Legalized?" Palliative Medicine 15 (2001): 61-65 at 63.
63. M. Downey, "Care for Dying 'Needs Millions More Dollars,'" Sydney Morning Herald, March 26, 1997, at 6. Later, following pressure from churches and the Australian Medical Association, a further cut was avoided: J. Brough and G. Alcorn, "Howard Guarantees Palliative Care Funds," Sydney Morning Herald, March 27, 1997, at 6.
64. M. Downey, "Care for Dying 'Needs Millions More Dollars,'" Sydney Morning Herald, March 26, 1997, at 6. Later, following pressure from churches and the Australian Medical Association, a further cut was avoided: J. Brough and G. Alcorn, "Howard Guarantees Palliative Care Funds," Sydney Morning Herald, March 27, 1997, at 6.
65. R. Dworkin, "Assisted Suicide: the Philosophers' Brief," The New York Review of Books, March 27, 1997: 41-47.
66. L. Ganzini, H.D. Nelson, T.A. Schmidt, D.F. Kraemer, M.A. Delorit, and M.A. Lee, "Physicians' Experiences with the Oregon Death with Dignity Act," N. Engl. J. Med. 342 (2000): 557-63.
67. L. Ganzini, H.D. Nelson, M.A. Lee, D.F. Kraemer, T.A. Schmidt, and M.A. Delorit, "Oregon Physicians' Attitudes About and Experiences With End-of-Life Care Since Passage of the Oregon Death with Dignity Act," JAMA 285 (2001): 2363-69.
68. L. Ganzini, T.A. Harvath, A. Jackson, E.R. Gov, L.L. Miller, and M.A. Delorit, "Experiences of Oregon Nurses and Social Workers with Hospice Patients Who Requested Assistance with Suicide," N. Engl. J. Med. 347 (2002): 582-88.
69. Ganzini, supra note 53, at 562.
70. Ganzini, supra note 55.
71. J.H. Veldink, J.H. J. Wokke, G. van der Wal, V. de Jong, L.H. van den Berg, "Euthanasia and Physician-Assisted Suicide Among Patients with Amyotrophic Lateral Sclerosis in the Netherlands," N. Engl. J. Med, 346 (2002): 1638-44 (reporting on a Dutch study which found that, between 1994 and 1999, 20 percent of 203 patients with ALS died by euthanasia or assisted suicide); P.J.E. Bindels, A. Krol, E. van Ameijden, D.K.F. Mulder-Folkerts, J. A. R. van den Hoek et al., "Euthanasia and Physician-Assisted Suicide in Homosexual Men with AIDS," The Lancet 347 (1996): 499-505 (reporting on a Dutch study in which 22 percent of men with AIDS died through assisted suicide or euthanasia, 12 times the national euthanasia rate of 2.1 percent).
72. J.H. Veldink, J.H. J. Wokke, G. van der Wal, V. de Jong, L.H. van den Berg, "Euthanasia and Physician-Assisted Suicide Among Patients with Amyotrophic Lateral Sclerosis in the Netherlands," N. Engl. J. Med, 346 (2002): 1638-44 (reporting on a Dutch study which found that, between 1994 and 1999, 20 percent of 203 patients with ALS died by euthanasia or assisted suicide); P.J.E. Bindels, A. Krol, E. van Ameijden, D.K.F. Mulder-Folkerts, J. A. R. van den Hoek et al., "Euthanasia and Physician-Assisted Suicide in Homosexual Men with AIDS," The Lancet 347 (1996): 499-505 (reporting on a Dutch study in which 22 percent of men with AIDS died through assisted suicide or euthanasia, 12 times the national euthanasia rate of 2.1 percent).
73. See M. Battin, Ethical Issues in Suicide (New Jersey: Prentice Hall, 1995): at 201, 225.
74. Emanuel, supra note 49.
75. New York State Task Force on Life & the Law, supra note 22 (Executive Summary). See also id. at 120ff.
76. T.O. Nielsen, "Guidelines for Legalized Euthanasia in Canada: A Proposal," in M. Somerville, ed., Death Talk: The Case Against Euthanasia and Physician-Assisted Suicide (Montreal & Kingston: McGill-Queen's University Press, 2001): 144-53, at 145.
77. J. Fitzgerald, "Bioethics, Disability and Death: Uncovering Cultural Bias in the Euthanasia Debate," in J. Jones and L.A. Basser Marks, eds., Disability, Divers-ability, and Legal Change (The Hague: Martinus Nijhoff, 1999): 267-81, at 272.
78. Miles, supra note 14, at 1787 and 1786, respectively. See also New York State Task Force on Life & the Law, supra note 22, at 121-24. 65. Somerville, supra note 15, at 24-85.
79. D. Callahan, "Good Strategies and Bad: Opposing Physician-Assisted Suicide," Commonweal 126 (December 3, 1999): 7.
80. Byock, supra note 27, at 2. Ian Maddocks, an Australian pioneer in palliative care, states that "What I do not want...is to see a brisk new expectation arise in our society that a quick death is a noble one, that for the sake of the family, the health budget or the stress upon carers, it will be best to elect euthanasia. This is because I feel that some of the excellent sharing and exchanges of love that inspire and comfort the rest of us will be lost in accepting that fatal attraction, and our society will be the poorer for it." I. Maddocks, "Hope in Dying: Palliative Care and a Good Death," in J. Morgan, ed., An Easeful Death? Perspectives on Death, Dying and Euthanasia (Sydney: Federation Press, 1996): 57-70, at 70.
81. Pollard and Winton argue, for example, that "Killing the failures of medical or social care would be negative, in that it would not contribute to finding solutions to their problems": B. Pollard and R. Winton, "Why Doctors and Nurses Must Not Kill Patients," Medical Journal of Australia 158 (1993): 426-29, at 428.
82. G. den Hartogh, "The Slippery Slope Argument," in H. Kuhse and P. Singer, eds., A Companion to Bioethics (Oxford: Blackwell Publishers Inc, 1998): 280-290, at 289.
83. den Hartogh, supra note 69, at 287.
84. Somerville, supra note 15, at 54.
85. Somerville, supra note 15, at 56.
86. Magnusson, supra note 6. at 200-29.
87. See Hillyard and Dombrink, supra note 10.
88. See P.R. Muskin, "The Request to Die: Role for a Psychodynamic Perspective on Physician-Assisted Suicide," JAMA 279 (1998): 323-28.
89. Hillyard and Dombrink, supra note 10, at 167-74.
90. Hillyard and Dombrink quote Dr Greg Hamilton, a Portland psychiatrist, who stated "I suppose in the death camps in various military movements there have been rules and guidelines about how to carry out the procedures at death camps, but that doesn't make it right": Hillyard and Dombrink, supra note 10, at 173. See, further, N.G. Hamilton, "Oregon's Culture of Silence," in K. Foley and H. Hendin, eds., The Case Against Assisted Suicide (Baltimore: The Johns Hopkins University Press, 2002): 175-91.
91. Hillyard and Dombrink, supra note 10, at 174.
92. See J.A. Tulsky, R. Ciampa, E. J. Rosen, for the University of Pennsylvania Center for Bioethics Assisted Suicide Consensus Panel, "Responding to Legal Requests for Physician-Assisted Suicide," Annals of Internal Medicine 132 (2000): 494-99; L. Snyder and A.L. Caplan, "Assisted Suicide: Finding Common Ground," Annals of Internal Medicine 132 (2000): 468-69.
93. See J.A. Tulsky, R. Ciampa, E. J. Rosen, for the University of Pennsylvania Center for Bioethics Assisted Suicide Consensus Panel, "Responding to Legal Requests for Physician-Assisted Suicide," Annals of Internal Medicine 132 (2000): 494-99; L. Snyder and A.L. Caplan, "Assisted Suicide: Finding Common Ground," Annals of Internal Medicine 132 (2000): 468-69.
94. See, e.g., D. Asch, "The Role of Critical Care Nurses in Euthanasia and Assisted Suicide," N. Engl. J. Med. 334 (1996): 1374-79.
95. Keown, supra note 45, at 63.